The ATO has been under significant scrutiny in light of the "Tik-Tok tax fraud" estimated to have cost the Government billions. The scandal involved taxpayers lodging incorrect business activity statements to receive refunds. The ATO launched Operation Portago in response.

Explain where this activity would fall on the "continuum of taxpayer behaviour" and why. Discuss what action the ATO may take to hold a taxpayer accountable. You are required to cite relevant law and secondary material.